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UNSC Sanctions List: Two Terror Entries Removed

Current · Source: Reserve Bank of India · RBI/2020-21/101 · issued 22 Feb 2021 · ~2 min read
Quick answerRBI directs all regulated entities to delete two individuals from UNSC sanctions lists per UAPA Section 51A. Banks must update screening databases and ensure no accounts exist for delisted persons.
Sanctions-list safety note. This circular refers to a specific UN Security Council / UAPA designated-entities list update as it stood on the date above — sanctions lists change often, and a newer update almost certainly exists today. Never use this page, or any single dated circular, as your current screening list. Always screen against the live, current list at the official UAPA proscribed-organisations list and the UN Consolidated List, and confirm the obligations for your bank on the official rbi.org.in source below.
The rule, in the simplest words
How it plays out — a real example

A payments & clearing officer in Indore checks her bank's AML (anti-money laundering) screening system every morning. Today, she sees a notification from RBI saying two names—Said ben Abdelhakim ben Omar al-Cherif and Emrah Erdogan—have been removed from the UNSC sanctions list. She immediately updates the system to remove those names, then reviews a customer's account that was frozen last year due to one of those names, and lifts the freeze so the customer can access their money again.

What changed

The UNSC removed two entries from its ISIL (Da'esh) & Al-Qaida Sanctions List: Said ben Abdelhakim ben Omar al-Cherif and Emrah Erdogan. RBI has advised all regulated entities to take note of this deletion and ensure compliance with the updated list.

What it means for you

Banks and lenders must immediately update their AML/KYC screening systems to remove these two individuals from their watchlists. This ensures that frozen accounts or restrictions on these persons are lifted in line with UNSC directives. Failure to update could lead to compliance gaps or customer grievances.

What you must do

Who it affects

All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Other RBI-regulated entities

❓ Common questions

What is the basis for this RBI circular?

It is issued under Section 51A of the Unlawful Activities (Prevention) Act, 1967, and references the Master Direction on KYC dated February 25, 2016 (as amended). The UNSC removed two entries from its sanctions list via press release SC/14440 dated February 19, 2021.

How should we handle accounts of the delisted individuals?

You must update your screening systems to remove these names from watchlists. Any accounts or assets frozen solely due to these entries should be unfrozen, subject to other legal obligations. Ensure compliance with RBI's KYC master direction.

Where can we find the updated UNSC sanctions list?

The updated list is available at www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list. The UNSC press release and details on delisting procedures are also linked in the RBI circular.

📜 Read the original circular — full text as issued by RBI
RBI/2020-21/101 DOR.AML.BC.No.42/14.06.001/2020-21   February 22, 2021 The Chairpersons/ CEOs of all the Regulated Entities Madam/Dear Sir, Implementation of Section 51A of UAPA, 1967: Updates to UNSC’s 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List – Deletion of two entries Please refer to Section 51 of our Master Direction on Know Your Customer dated February 25, 2016 as amended on December 18, 2020 , in terms of which “Regulated Entities (REs) shall ensure that in terms of Section 51A of the Unlawful Activities (Prevention) (UAPA) Act, 1967, they do not have any account in the name of individuals/entities appearing in the lists of individuals and entities, suspected of having terrorist links, which are approved by and periodically circulated by the United Nations Security Council (UNSC).” 2. In this regard, Ministry of External Affairs (MEA) has now forwarded the following Press Release issued by the United Nations Security Council (UNSC) Committee established pursuant to Resolutions 1267 (1999), 1989 (2011) and 2253 (2015) concerning ISIL (Da’esh), Al-Qaida, and associated individuals, groups, undertakings and entities regarding changes in the List of individuals and entities subject to the assets freeze, travel ban and arms embargo set out in paragraph 1 of UNSC resolution 2368 (2017), and adopted under Chapter VII of the Charter of the United Nations. Note SC/14440 dated 19 February 2021 deleting two entries to list of individuals in UNSC’s 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List viz. [QDi.138 Name: 1: SAID 2: BEN ABDELHAKIM 3: BEN OMAR 4: AL-CHERIF ] and [QDi.362 Name: 1: EMRAH 2: ERDOGAN 3: na 4: na] The UNSC press release concerning amendments to the list is available at URL: https://www.un.org/securitycouncil/sanctions/1267/press-releases 3. Updated lists of individuals and entities linked to ISIL (Da'esh), Al-Qaida and Taliban are available at: www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list https://www.un.org/securitycouncil/sanctions/1988/materials 4. The details of the sanctions measures and exemptions are available at the following URL: https://www.un.org/securitycouncil/sanctions/1267#further_information 5. As per the instructions from the Ministry of Home Affairs (MHA), any request for delisting received by any Regulated Entity (RE) is to be forwarded electronically to Joint Secretary (CTCR), MHA for consideration. Individuals, groups, undertakings or entities seeking to be removed from the Security Council’s ISIL (Da'esh) and Al-Qaida Sanctions List can submit their request for delisting to an independent and impartial Ombudsperson who has been appointed by the United Nations Secretary-General. More details are available at the following URL: https://www.un.org/securitycouncil/ombudsperson/application 6. In view of the above, REs are advised to take note of the aforementioned UNSC communication and ensure meticulous compliance. Yours faithfully, (Vivek Srivastava) General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2020-21/101 · issued 22 Feb 2021. The plain-English explanation above is BankPulse’s own independent summary.
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Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Other RBI-regulated entities), your first concrete step on “UNSC Sanctions List: Two Terror Entries Removed” is: “Update your AML screening databases to remove the two delisted individuals from sanctions watchlists.” (RBI issued this 22 Feb 2021).

  1. Circular: RBI/2020-21/101 -- UNSC Sanctions List: Two Terror Entries Removed
  2. Issued: 22 Feb 2021
  3. Action required: Update your AML screening databases to remove the two delisted individuals from sanctions watchlists.
  4. Action required: Review any accounts or transactions previously frozen due to these entries and take appropriate action as per RBI guidelines.
  5. Action required: Ensure internal compliance teams are aware of the UNSC press release and the updated sanctions list available on UN website.
  6. Action required: Forward any delisting requests received from customers to Joint Secretary (CTCR), MHA as per MHA instructions.
  7. Owner: ____________ Target date: ____________
  8. Board/committee approval needed? Y / N
  9. Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12033&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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